People v. Viernes

G.R. No. 118091 (October 3, 1996)

Viernes, Sosa, Unciano, and Patulay were acquitted of murder; self-defense cited due to insufficient evidence.

Facts:

On December 19, 1991, in Buguey, Cagayan, a stabbing incident occurred resulting in the death of Herminio Doniego. The provincial prosecutor filed an information against Wilfredo Viernes, Joel Sosa, Cornelio Unciano, and Romy Patulay for murder, alleging that they conspired to kill Doniego, taking advantage of their superior strength and acting with evident premeditation and treachery. During the arraignment, Viernes pleaded guilty but requested to explain his plea, while the other three accused pleaded not guilty.

The trial court found the accused guilty of murder, qualifying the crime with evident premeditation and aggravating circumstances of abuse of superior strength and nighttime. The court sentenced them to reclusion perpetua and ordered them to pay damages to the heirs of the deceased.

The prosecution presented five witnesses, including Sonny Doniego and Dionisio Crisostomo, who testified that they saw Viernes stab Herminio while the other accused held him. The defense, particularly that of Viernes, claimed self-defense, stating that he was attacked first by Herminio, who had pushed his head and subsequently slashed his back with a razor.

The other accused presented alibi defenses, claiming they were not present at the scene of the crime. The trial court concluded that the prosecution had established the guilt of the accused beyond reasonable doubt, citing the conspiracy among them.

Legal Issues:

  1. Whether Wilfredo Viernes acted in self-defense.
  2. Whether there was conspiracy among the accused in the commission of the crime.
  3. Whether the aggravating circumstances of nighttime and abuse of superior strength were present.

Arguments:

  • Prosecution's Argument:

    • The prosecution argued that the testimonies of its witnesses established a clear narrative of conspiracy and premeditation. They contended that Viernes stabbed Herminio while the other accused held him, demonstrating a coordinated attack. The prosecution also maintained that the aggravating circumstances were present, justifying the conviction for murder.

  • Defense's Argument:

    • The defense, particularly for Viernes, asserted that he acted in self-defense, having been attacked first by Herminio. They argued that the prosecution failed to prove conspiracy, as there was no evidence of a prior agreement to kill. The defense also contended that the prosecution's evidence was insufficient to establish the presence of the alleged aggravating circumstances.

Court's Decision and Legal Reasoning:

The court reversed the trial court's decision, acquitting all accused. It found that Viernes had sufficiently proven the elements of self-defense. The court noted that:

  1. Unlawful Aggression: The court recognized that Herminio's actions constituted unlawful aggression, as he had attacked Viernes first by pushing his head and subsequently slashing his back with a razor.

  2. Reasonable Necessity: The court held that the means employed by Viernes to repel the attack (stabbing Herminio) were reasonable under the circumstances, as he was responding to an immediate threat to his safety.

  3. Lack of Provocation: The court concluded that any provocation by Viernes was not sufficient to justify the violent response from Herminio.

The court also found that the prosecution failed to establish conspiracy among the accused, as there was no evidence of a preconceived plan or agreement to commit the crime. The testimonies of the prosecution witnesses did not convincingly demonstrate a coordinated effort to kill Herminio.

Significant Legal Principles Established:

  1. Self-Defense: The ruling reaffirmed the principles of self-defense, emphasizing that the burden of proof shifts to the accused to establish the elements of self-defense when claimed. The court highlighted that instinctive reactions to immediate threats are justifiable under the law.

  2. Conspiracy: The decision underscored the necessity of proving conspiracy with clear and convincing evidence, requiring a logical relationship between the actions of the accused and a common design to commit the crime.

  3. Aggravating Circumstances: The court reiterated that the presence of aggravating circumstances must be established beyond reasonable doubt, and the absence of motive can be significant in determining the truth in conflicting narratives.